Legal Opinion

Ryan v. Commissioner

United States Tax Court

Decided April 24, 1972No. Docket No. 4800-69PublishedCited by 5 opinions

Respondent's application for order to take depositions on written interrogatories of Swiss bank officials in Switzerland for the purpose of identifying and authenticating the records of the bank pertaining to the bank accounts maintained or controlled by petitioner, granted.

1Opinion of the Court

OPINION

Drennen, Judge:

Respondent filed an Application For An Order to Take Depositions Upon Written Interrogatories of such officers and employees of the Commercial Credit Bank, Ltd. (Handelskredit Bank, A.G.), Zurich, Switzerland, as may be necessary to establish through the testimony of such officers and employees the bank records and accounts, and transactions therein, maintained or controlled by petitioner Baymond J. Byan, in said bank or on behalf of said bank during the years 1958 to 1968, inclusive; and to follow a procedure agreed upon between the Swiss taxing authorities and the U.S.…

2Cases cited5 opinions

  1. American Farm Lines v. Black Ball Freight ServiceSupreme Court of the United States · 1970
  2. United States v. BreitlingSupreme Court of the United States · 1858
  3. Gondeck v. Pan American World Airways, Inc.Supreme Court of the United States · 1965
  4. Board of Tax Appeals v. United States ex rel. Shults Bread Co.Court of Appeals for the D.C. Circuit · 1929
  5. In Re Laytan Jewelers, Inc.District Court, S.D. New York · 1971

3Cited by5 opinions

  1. Ryan v. CommissionerUnited States Tax Court · 1976
  2. Durovic v. CommissionerUnited States Tax Court · 1985
  3. Durovic v. CommissionerUnited States Tax Court · 1985
  4. Ryan v. CommissionerUnited States Tax Court · 1976
  5. Ryan v. CommissionerUnited States Tax Court · 1972

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